Conflict of interest policy

Valorlife Lebensversicherungs-AG (hereafter “Valorlife”) provides
life insurance products designed for demanding clients. These
products are made available to clients only by authorised independent
professional advisers.

When conducting business, we understand at Valorlife that each
party has specific interests which possibly can be conflicting with the
interests of the other party or parties.

For Valorlife, integrity is a core value in its relationship with its clients
and partners, and in order to prevent, to manage or to remedy such
potential conflictual situations, Valorlife has adopted a Conflicts of
Interest Policy (the “Policy”). The Policy sets out a list of identification
criteria and a list of processes and measures implemented to prevent
or manage situations of possible conflicts of interest which could
arise, or address such conflict of interests when they have occurred,
between Valorlife, its shareholders and employees and its clients on
the one hand or between its different clients on the other hand.

Therefore, the Policy allows Valorlife not only to comply with
regulatory requirements, but also to promote a culture of integrity
and to apply the highest standards of ethical conduct in its relationship
with clients.

Valorlife wishes to inform clients about the Policy and has therefore
summarised its key aspects in this document.

Identification of potential conflicts of interest:
The client acknowledges and accepts that Valorlife, or a relevant
person, or a person directly or indirectly linked by a relationship
of control to Valorlife (a “Third Party”) is entitled to provide services
to, or effect transactions with or for the client notwithstanding that
Valorlife may have a material interest in, or a conflict of duty with regard to or related to the service or transaction. The client also
acknowledges and accepts that Valorlife shall operate in any manner
that it deems appropriate in such cases.

Valorlife has identified the following circumstances where a potential
conflict of interest may primarily arise when Valorlife or a Third Party
provides services in relation to the life insurance contract to the client
for example when:

1. Valorlife or a Third Party is likely to make a financial gain, or avoid
a financial loss, at the expense of the client.
2. Valorlife or a Third Party has an interest in the outcome of
a service provided to the client or of a transaction carried out on behalf
of the client, distinct from the client’s interest in that outcome.
3. Valorlife or a Third Party has a financial or other incentive
to favour the interest of another client or group of clients over
the interests of the client.
4. Valorlife or a Third Party carries on the same business
as the client.
5. Valorlife or a Third Party receives or will receive from a person
other than the client an inducement in relation to a service provided
to the client, in the form of monies, goods or services, other than the
standard commission or fee for that service.

Valorlife has in place various procedures and takes a number of
specific measures to actively manage potential conflicts of interest
and thus to minimise any risk of damage to client interests, including:

1. Organisational provisions, such as the segregation of tasks likely
to create conflicts of interest, a remuneration policy preventing
profit-sharing directly linked to the success of a specific transaction,
procedures relating to personal transactions initiated by its employees
or measures in relation to employee training.

2. Information barriers and other provisions aiming to prevent, or
restrict to the bare essential, the transfer of sensitive information
between persons or entities involved in activities where a conflict of
interests may arise.

3. Compulsory ban on Valorlife itself, its directors, its executives
and its employees on accepting advantages from entities having
significant interests in the underwriting or administration process of
a life insurance contract. However, gifts or minor tokens of hospitality
of a value lower than the threshold fixed by the Policy will not be
considered as an advantage in this respect.

4. Physical, electronic and operational information barriers are
set up in order to prevent and control the circulation of confidential
information between persons who are exposed to conflicts of interest
within the organisation, if such circulation of information could harm
the interests of one or more clients.

5. Electronic barriers allow, for example only employees in charge
of a specific contract to have access to their personal details.

6. Examples of electronic barriers are special electronic security
systems and mandatory passwords for obtaining access to certain
information.

7. At an operational level, the business areas concerned are
managed by different persons who must comply with the joint
signature requirements according to internal procedures in order
to prevent/limit the possible exercise of an improper influence
by one of those directors or employees only.

A temporary departure from these principles is only allowed in
exceptional circumstances. Any such departure must be justified and
is meticulously supervised. As a result, Valorlife offers services under
the agreement regulating the business relationship between Valorlife
and the client on the basis of information known only to specific
employees responsible for the management of client affairs.

Assessment of situations of conflicts of interests:
In cases where all reasonable efforts and measures taken
to prevent conflicts of interest are not deemed sufficient to ensure
with reasonable confidence that risks of damage to client interests will
be prevented, or that these situations of conflicts cannot be managed
in order to prevent a risk of damage to the client, Valorlife will consider
whether a disclosure is appropriate or whether it is in the client’s best
interests to refrain from undertaking business on his behalf.

In certain circumstances Valorlife may disclose to the client, in a
durable medium, the general nature and, as the case may be, the
source of the conflict of interest, enabling the client to make an
informed decision with respect to the service in the context of which
the conflict of interest arises.

Where Valorlife considers that the risk of damage to client interests
is too substantial, it will refuse to undertake business with the
client. Therefore, Valorlife reserves the right in some circumstances
to decline to provide services or execute transactions with or for
the client directly, in connection with the insurance contract as
a consequence of Valorlife’s relationship with other clients, its
shareholders or employees. In this event, Valorlife shall not have any
disclosure obligations regarding the reasons for its refusal.

Update of the Policy
The Policy will be updated regularly, taking into account, in particular,
changes in legislation, new services and products offered by Valorlife.